Revenue have issued a Statement of Practice on their website in relation to Foreign Branch Double Taxation Relief.
This statement addresses an issue, that particularly affects the insurance industry, relating to double tax relief for foreign tax paid by foreign branches of Irish companies.
Where unrelieved double taxation occurs due to a timing difference regarding recognition of income between Ireland and a foreign jurisdiction, relief may be available under the Statement of Practice.
This timing difference can arise due to a difference in local tax or accounting rules, thereby giving rise to unrelieved double taxation. This Statement of Practice is in relation to foreign tax paid for periods commencing on or after 1 January 2013. (Source: Revenue)
All the best,
The Team at Jefferson